Brown v. Montefiore Medical Center
- Paul Gardephe
- 1:18-cv-03861
- U.S. District Court · Southern District of New York
- 2
In Brown v. Montefiore Medical Center, Judge Gardephe denied without prejudice Defendants’ motion to seal deposition portions, allowing narrower redactions.
The defendants’ request to publicly file Guelda Brown’s deposition transcript with redactions was denied without prejudice; the court allowed a narrower sealing request focused on medical information.
What happened
In Brown v. Montefiore Medical Center, the defendants asked to file Guelda Brown’s deposition transcript with redactions covering information about her medical condition. They submitted a public version with proposed redactions and an unredacted version under seal for review in connection with their pending summary-judgment motion.
The defendants said the redacted portions had been marked confidential under an agreement between the parties. The court explained that confidentiality agreements and the parties’ consent do not alone overcome the public’s right to access court records.
Judge Paul G. Gardephe denied the defendants’ motion to seal without prejudice. He said redactions could cover discussion of Brown’s medical records, treatment, and diagnoses, but had to be narrowly limited to that information rather than covering entire pages. The court stated that any further motion to seal had to be filed by July 19, 2023.
The detailed version
- Brown v. Montefiore Medical Center · No. 1:18-cv-03861
- Paul Gardephe
- July 12, 2023
Background
The defendants—Montefiore Medical Center, Aretha Mack, Veronica Crute, and Anthony Leung—asked to file a complete transcript of Guelda Brown’s deposition with some portions removed from the public version. The proposed redactions concerned Brown’s medical condition and portions that the parties had designated as confidential. The request arose while the defendants’ motion for summary judgment was pending.
The defendants publicly filed the proposed redacted transcript and filed an unredacted copy under seal for the court’s review. They asked the court to approve the redacted filing.
Court’s analysis
The court applied the presumption that judicial documents should be publicly accessible. It stated that a redaction or sealing request must be narrowly tailored to the interest supporting it. The parties’ agreement that information was confidential, or their consent to sealing, was not by itself enough to overcome public access.
The court concluded that discussion of Brown’s medical records, treatment, and diagnoses could be proper subjects for redaction. But the proposed redactions had to be limited to that information and could not redact entire pages of the deposition.
Disposition
The court denied without prejudice the defendants’ motion to seal. It stated that any further motion to seal had to be filed by July 19, 2023. Judge Paul G. Gardephe signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.